Workshop: Learning from CSRD Reporting

This week, Technological University Dublin had the pleasure of hosting Business in the Community Ireland 's workshop for its members aimed at sharing insights from the first wave of CSRD compliant reports. Notwithstanding regulatory uncertainty associated with the Omnibus, with circa. 50 participants, it was evident from engagement that sustainability reporting, as we know it, is only getting started. There were several key highlights.

Etain Kidney shared with pride that TU Dublin was awarded the prestigious AASHE through its global Sustainability Tracking, Assessment and Rating System (STARS®). In terms of sustainability reporting, STARS is as rigorous as it gets. So, the accreditation places TU Dublin as Europe’s highest-ranked university amongst nearly 600 institutions worldwide. Bravo to colleagues in the sustainability office - Mark Z. and Philippe Lemarchand .

Neela Couture provided an overview of published insights from the first wave of CSRD reporting. Companies are still adjusting, evident in the wide variation in report lengths (30 to over 300 pages) and the number of reported sustainability-related impacts, risks, and opportunities (IROs), ranging from under 15 to over 80. It suggests that best practices are still evolving, which can make comparisons difficult. Most companies seem to be recognising the strategic significance of double materiality analysis. However, there is still room for improvement in integrating it into business models and strategies. Signposting by reference has emerged as a common practice to avoid duplication of content. ESRS S1 (own workforce), E1 (climate), and G1 (business conduct) are the most frequently reported material topics. Conversely, ESRS E2 (pollution), E3 (marine resources), and G1 (animal welfare) were among the least covered. Many companies disclosed a climate transition plan, although some did not fully address all ESRS elements, such as alignment with the 1.5°C. Companies also faced challenges in mapping their value chains and standardizing ESG reporting processes. Whilst the predominant form of assurance observed was limited assurance, the audit process has led to more rigorous assessments of materiality.

Dr Ciarán O'Carroll gave an excellent overview of the EU Omnibus, which affects CSRD, the EU Taxonomy, CSDD and CBAM. The most immediate change is the proposed two-year postponement of reporting for "Wave 2" (large non-listed) and "Wave 3" (listed SMEs) companies. Some wave 2 repoters have opted to proceed, whilst others have pressed pause. The uncertainty surrounding in-scope companies, in terms of thresholds for employees, turnover and balance sheet is, itself, creating risk. The Omnibus seeks to ensure smaller companies are not unduly burdened. Information requested by large companies of SMEs in their value chains may be limited to what is specified in new "voluntary" VSME standards. The EU's Stop-the-Clock" Directive, adopted in April, formally postpones the application dates of certain CSRD requirements. Member States, including Ireland, must transpose this directive into national legislation by December 31, 2025.

Laura Morrison facilitated an excellent deep-dive into materiality assessments, IRO's and stakeholder engagement of published reports, including those of AIB , Bank of Ireland , The Kerry Group, LLC and Glenveagh Properties plc . Achieving a balance between data completion and narrating a compelling story was a recurrent theme. Given that Wave 1 reports mark the genesis of standardised reporting, benchmarking, and year-on-year comparisons have yet to crystallise. However, specificity on timeframes and direction of travel were identified as possible areas for improvement. There was also perceived variation in oversight and governance. In reporting impact materiality, negative impacts tended to outnumber positive impacts. In a similar vein, risks tended to outnumber opportunities in disclosing financial materiality. There was also a wide variation in material topics identified. Interestingly much of the discussions on these reports were consistent with the analysis using Sustainability Reporting Navigator 's AI tool. Given the size and textual nature of these reports, AI is a sine qua non for effective analysis and insights.

The panel discussion with Fiona Gaskin and Jill Shaw was also extremely useful. Their experience in working with several Wave 1 and Wave 2 reporters shed light on the core issues, including the current uncertainty concerning the regulatory, risk and compliance. A central tenet of their advice was to invest time in understanding the core data requirements, to focus on bringing clarity to material topics and to engage with auditors early in the process. Perhaps, the most valuable aspect of the workshop was simply the opportunity to network, share the pain-points of sustainability reporters, building much needed capacity.

The workshop concluded with a snapshot from Linda Mc Weeney of TU Dublin's new online PG Certificate in Sustainability Reporting, which covers impact reporting, sustainability regulatory compliance and transformation, and sustainability assurance. Dr Ciarán O'Carroll also gave a snapshot of the PG Certificate in Sustainability Leadership, which is 90% funded under the Human Capital Initiative (Springboard) initiative.

A particular thanks to Business in the Community Ireland for involving this initiative and to colleauges who contributed Lesley Murphy , Ruth O'Leary , Pearlean Chadha , Dr Ciarán O'Carroll , Dr. Cormac MacMahon and Linda Mc Weeney .